Supplier & Partner Code of Conduct

AQNOVA MARKETPLACE

Global Legal Footer Framework

Comprehensive Compliance & Platform Governance Reference

(MASTER)

Minimum Standards for Labour Practices, Environmental Management, Business Integrity & Legal Compliance for All AqNova Suppliers, Vendors, Logistics Partners, Payment Processors & Technology Suppliers

Effective Date: April 7, 2026 | Version 1.0 | Arivon Holding Corporation

AqNova's Supplier & Partner Code of Conduct establishes the minimum ethical, labour, environmental, and business integrity standards that all entities supplying goods or services to AqNova must meet as a condition of their commercial relationship with Arivon Holding Corporation. The Code applies universally — to a small artisan Vendor selling handmade candles on AqNova, a global logistics company managing AqNova's freight, and a major cloud provider hosting AqNova's Platform. The specific requirements relevant to each supplier type are weighted by risk and applicability.

AqNova's Code is calibrated against internationally recognized standards including the ILO Core Conventions, the Responsible Business Alliance (RBA) Code of Conduct, the Ethical Trading Initiative (ETI) Base Code, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises. Compliance with this Code is a contractual obligation; material violations may result in termination of the commercial relationship.

7.4.1 Labour & Human Rights Standards

All suppliers must respect the fundamental labour rights of workers in their operations, calibrated against the ILO Core Conventions and the ETI Base Code:

A. Freely Chosen Employment — No Forced Labour

B. No Child Labour

Suppliers must not employ workers below the minimum legal working age in their jurisdiction, with an absolute minimum of 15 years of age (consistent with ILO Convention C138). For hazardous work, the absolute minimum age is 18 years.

The worst forms of child labour (ILO Convention C182) are absolutely prohibited — including trafficking, sexual exploitation, use in armed conflict, and hazardous work.

Young workers (15–17 where legally permitted): suppliers employing young workers must ensure restricted working hours, no hazardous tasks, no night work, and protection of access to education.

Age verification: suppliers must maintain documented age verification procedures (government-issued ID) for all workers and preserve records for a minimum of 5 years.

Child labour remediation: where child labour is discovered, suppliers must prioritize the welfare of the child — including educational support and family welfare assistance — over immediate dismissal.

C. Freedom of Association & Collective Bargaining

Suppliers must respect workers' rights to form or join trade unions or worker organizations of their choosing, without interference, harassment, or retaliation.

Where freedom of association is legally restricted, suppliers must provide effective alternative mechanisms for worker collective representation (works councils; workplace committees).

Suppliers must bargain in good faith with freely chosen worker representatives on wages, working conditions, and other relevant matters.

Anti-retaliation: no worker may be disciplined, demoted, dismissed, or penalized for exercising rights to organize, bargain collectively, or participate in lawful industrial action.

D. Non-Discrimination & Equal Opportunity

Suppliers must not discriminate in hiring, promotion, compensation, discipline, or termination based on: race, colour, sex, religion, political opinion, national extraction, social origin, disability, age, sexual orientation, gender identity, pregnancy, marital status, caste, or any other characteristic protected by applicable law.

Equal remuneration for work of equal value is required, consistent with ILO Convention C100.

Suppliers must have a documented non-discrimination policy communicated to all workers and management.

Migrant workers must receive the same employment conditions as comparable local workers. Recruitment fees must not be charged to workers — the employer bears all recruitment costs (Dhaka Principles for migrant worker recruitment).

E. Wages & Benefits

Suppliers must pay workers at least the legally required minimum wage in their jurisdiction, paid in full, on time, and in legal tender.

Wages must not be subject to deductions that are not permitted by applicable law or that bring net pay below the legal minimum.

Overtime must be compensated at the premium rate required by applicable law.

AqNova strongly encourages suppliers to work toward payment of a living wage — a wage sufficient to meet workers' basic needs with a modest discretionary amount — benchmarked against the Anker Living Wage Reference Values or equivalent national benchmark.

Workers must receive regular, comprehensible payslips documenting all earnings and deductions.

All legally required benefits (social insurance, health, pension, maternity/paternity leave) must be provided.

F. Working Hours & Rest

Regular working hours must not exceed 48 hours per week. Total hours including overtime must not exceed 60 hours per week except in genuine, time-limited exceptional circumstances.

All overtime must be voluntary. Workers must be able to decline overtime without penalty, dismissal, or demotion.

Workers must receive at least one rest day per seven-day period. Daily rest between shifts must be at least 11 hours.

Workers are entitled to annual leave as required by applicable law. Annual leave must be taken and cannot be routinely bought out as a substitute for rest.

G. Humane Treatment

No worker may be subjected to corporal punishment, physical or psychological harassment, verbal abuse, coercion, or intimidation.

Suppliers must have documented policies prohibiting harassment and providing grievance mechanisms for workers to raise concerns about treatment without fear of retaliation.

Disciplinary processes must be documented, fair, and consistent. Disciplinary measures must not include punitive wage deductions beyond what is permitted by applicable law.

7.4.2 Health, Safety & Wellbeing

Suppliers must provide safe, healthy, and humane working conditions for all workers. AqNova's health and safety requirements are based on ILO Convention C155 (Occupational Safety and Health Convention), the ETI Base Code, and applicable national health and safety law:

A. Facility Safety Minimum Requirements

Building structural integrity: all production and operational facilities must be structurally sound and assessed for structural safety risks. Where doubt exists about structural integrity, independent assessment must be conducted.

Fire safety: unobstructed emergency exits at all times during working hours; functioning fire detection and suppression systems; evacuation drills at minimum twice annually; clear and posted emergency evacuation plans.

Chemical safety: all hazardous chemicals must be labelled in compliance with applicable GHS/CLP standards; Safety Data Sheets (SDS) available in workers' language; appropriate PPE provided at no cost to workers; chemical handling training provided.

Machine safety: all dangerous machinery with appropriate guarding; lockout/tagout procedures; machine-specific safety training before workers operate machinery.

Electrical safety: all electrical systems properly installed and maintained; regular inspection of electrical equipment; no exposed wiring or unsafe electrical installations.

Sanitation and hygiene: clean drinking water available at all times; adequate, clean, and segregated sanitation facilities; hygiene facilities for food preparation or handling contexts.

Ventilation and temperature: adequate natural or mechanical ventilation; temperature maintained within safe ranges; protection from excessive heat, cold, dust, fumes, and noise.

Personal protective equipment: appropriate PPE provided free of charge; use required in hazardous tasks; PPE maintained in usable condition.

B. Health & Safety Management

Occupational health: workers in high-risk occupations (chemical exposure, dust, noise, ergonomic risk) must have access to periodic health monitoring relevant to their occupational risk.

First aid: first aid facilities and trained first aiders available during all working hours; emergency medical response procedures documented and communicated.

Incident reporting: all workplace accidents, injuries, and near-misses must be recorded and reported to management. Serious injuries and fatalities must be reported to AqNova within 72 hours.

H&S Committee: facilities with 10 or more workers are expected to have a joint management-worker H&S Committee with authority to identify and address hazards.

Pregnancy protection: pregnant workers must not be assigned to tasks involving chemical exposure, heavy lifting, or other documented risks to pregnancy without explicit medical assessment and alternative task assignment.

C. Worker Wellbeing

Workers should have access to support resources for mental health and wellbeing challenges — appropriate to the scale and resources of the supplier.

Where on-site accommodation is provided, it must meet minimum standards for safety, privacy, hygiene, and habitability, and workers must not be required to reside on-site as a condition of employment.

7.4.3 Environmental Standards

AqNova's identity as a sustainable marketplace requires that its supply chain partners operate with genuine environmental responsibility. The following environmental standards apply to all suppliers, scaled to the supplier's size, sector, and environmental impact:

A. Legal Compliance

All suppliers must comply with applicable environmental laws and regulations in their jurisdiction of operation, including: environmental permit requirements; discharge and emission limits; waste management regulations; chemical restrictions; and reporting obligations.

Non-compliance with environmental law that results in criminal prosecution, significant regulatory enforcement, or material environmental harm constitutes a material breach of this Code.

B. Hazardous Substances

Suppliers must not use substances banned or restricted under: Stockholm Convention on Persistent Organic Pollutants (POPs); Montreal Protocol on Ozone Depleting Substances (ODS); Basel Convention on Hazardous Wastes; EU REACH Regulation (1907/2006/EC); or applicable national chemical restriction laws.

Suppliers must maintain records of all hazardous substances used in their operations and ensure proper handling, storage, labelling, and disposal consistent with applicable law.

For goods suppliers (Vendors): products must comply with applicable chemical restrictions in destination markets — including EU REACH Annex XVII, RoHS, CPSIA (US), and equivalent national standards. See also Section 7.4.6.

C. Environmental Management

Suppliers are encouraged to implement ISO 14001:2015-aligned Environmental Management Systems (EMS) or equivalent structured environmental management approaches.

Suppliers must identify their material environmental aspects and impacts: greenhouse gas emissions; water use; waste generation; chemical use; land use and biodiversity impact.

Suppliers should set and pursue documented improvement targets for their material environmental impacts, consistent with the Paris Agreement 1.5°C pathway where feasible.

D. GHG Emissions & Climate

Suppliers are encouraged to measure and disclose their Scope 1 and 2 GHG emissions consistent with the GHG Protocol Corporate Standard.

Major suppliers (above defined revenue threshold) will progressively be required to disclose Scope 1 and 2 emissions to AqNova as part of AqNova's Scope 3 supply chain emissions tracking under its SBTi-aligned targets.

Suppliers are encouraged to set Science Based Targets (SBTi-validated) for emission reduction, and to pursue 100% renewable electricity for their operations by 2030.

E. Water & Waste

Suppliers operating in water-intensive sectors or water-stressed regions (WRI Aqueduct) must implement water conservation measures and disclose water use intensity data to AqNova on request.

Suppliers must manage waste — including hazardous waste — in compliance with applicable law. Hazardous waste must be disposed of through licensed contractors.

Suppliers are encouraged to progress toward circular economy practices: waste reduction; reuse; recycling; recovery; moving away from single-use materials.

F. Deforestation-Free Sourcing

Suppliers in high-risk commodity sectors (palm oil, cocoa, coffee, soya, timber, rubber, beef) must demonstrate deforestation-free sourcing consistent with the EU Deforestation Regulation (2023/1115/EU) and applicable national environmental law.

AqNova gives preferential recognition to suppliers holding FSC, PEFC, RSPO, Rainforest Alliance, or equivalent deforestation-free certification.

7.4.4 Business Integrity & Anti-Corruption

All suppliers must conduct their business with integrity, in compliance with applicable anti-corruption, anti-bribery, and competition law. AqNova has zero tolerance for corruption in its commercial relationships.

A. Anti-Bribery & Anti-Corruption

B. Conflicts of Interest

Suppliers must disclose to AqNova any actual or potential conflict of interest in their commercial relationship with AqNova — including personal relationships between supplier personnel and AqNova employees, or competing financial interests.

Gifts and entertainment exchanged between suppliers and AqNova must be reasonable, proportionate, and consistent with applicable law and AqNova's Gifts and Entertainment Policy (maximum value: USD $75 per occasion per individual; no cash gifts).

C. Fair Competition & Antitrust

Suppliers must comply with applicable competition law — including the US Sherman Act, Clayton Act, EU TFEU Arts. 101–102, UK Competition Act 1998, and equivalent national law.

Suppliers must not enter into agreements with AqNova's competitors, or with other suppliers, that could constitute price-fixing, market allocation, bid-rigging, or other anticompetitive conduct.

Suppliers must not exchange competitively sensitive information (pricing; customer lists; commercial strategies) with competitors through AqNova's platform or in the context of their supplier relationship with AqNova.

D. Financial Integrity & Records

Suppliers must maintain accurate, complete, and transparent financial books and records relevant to their commercial relationship with AqNova.

Suppliers must not engage in money laundering, financial fraud, or tax evasion in connection with their commercial relationship with AqNova.

Suppliers must comply with applicable AML/CTF requirements and cooperate with AqNova's payment processor AML screening as required by applicable law.

7.4.5 Data Protection, Privacy & Information Security

Suppliers who handle personal data of AqNova's Buyers, Vendors, or employees — or who have access to AqNova's confidential systems and data — must comply with the following data protection and information security requirements:

A. Data Protection Compliance

All suppliers who process personal data on AqNova's behalf are data processors under GDPR (2016/679/EU), UK GDPR, and equivalent legislation, and are required to enter into a Data Processing Agreement (DPA) with Arivon Holding Corporation consistent with GDPR Article 28.

Suppliers must process personal data only for the purposes defined in the DPA and only on documented instructions from AqNova.

Suppliers must implement appropriate technical and organizational measures to ensure security of personal data against unauthorized access, accidental loss, destruction, or alteration.

Suppliers must promptly notify AqNova of any personal data breach affecting AqNova's data within 24 hours of becoming aware of the breach.

Suppliers must not transfer AqNova's personal data to third parties or sub-processors without AqNova's written consent and implementation of appropriate transfer safeguards.

Applicable data protection laws include: GDPR; UK GDPR; CCPA/CPRA (California); LGPD (Brazil); DPDPA (India); PDPA (Singapore, Thailand); PIPL (China); NDPR (Nigeria); POPIA (South Africa); and equivalent national laws in all operating jurisdictions.

B. Information Security

Technology suppliers, payment processors, and suppliers with system access must implement information security controls consistent with ISO/IEC 27001:2022 or equivalent recognized standard.

Payment processors and suppliers handling cardholder data must comply with PCI DSS v4.0 (Payment Card Industry Data Security Standard).

Suppliers must maintain documented information security policies, access control procedures, and incident response plans.

Suppliers must not use AqNova's data or systems for any purpose other than the performance of their contracted services.

Access to AqNova systems and data must be limited to personnel with a documented business need; access must be withdrawn immediately upon change of role or termination of the commercial relationship.

Security assessments: AqNova may request evidence of suppliers' information security controls (SOC 2 Type II report; ISO 27001 certificate; penetration test summary) as part of its supplier risk management program.

7.4.6 Product Safety & Compliance (for Vendors & Goods Suppliers)

Vendors (product sellers) and direct goods suppliers to AqNova have additional obligations relating to product safety, compliance, and labelling:

Product safety baseline: all products must comply with the EU General Product Safety Regulation (GPSR, 2023/988/EU) as AqNova's global baseline, plus applicable mandatory safety standards in destination markets (CPSC/CPSIA — US; CCPSA — Canada; ACL — Australia; NRCS — South Africa; SON/SONCAP — Nigeria; BIS — India; CCC — China; PSE — Japan; KC — South Korea; INMETRO — Brazil; and others as applicable). See Section 5.6 for full product compliance framework.

Documentation: Vendors must hold and be able to provide to AqNova on request: applicable conformity certificates; test reports from accredited laboratories; Declarations of Conformity; Safety Data Sheets; and any other documentation required by applicable law.

Traceability: Vendors must maintain supply chain traceability sufficient to identify and isolate affected batches in the event of a product safety incident. One-step-forward, one-step-back traceability is the minimum standard.

Incident reporting: Vendors must notify AqNova within 24 hours of becoming aware of any product safety incident, recall, regulatory enforcement action, or consumer complaint involving a significant safety risk for products listed on AqNova.

No counterfeit goods: Vendors must not sell counterfeit products — goods that infringe the trade marks, designs, or other intellectual property of third parties. Counterfeiting constitutes a material breach of the Vendor Agreement and this Code, resulting in immediate account termination.

Chemical compliance: products must comply with applicable chemical restrictions in destination markets, including EU REACH (SVHC disclosure; Annex XVII restrictions); UK REACH; RoHS; CPSIA lead and phthalate limits; and equivalent national chemical standards.

A. Intellectual Property Respect

Suppliers must not infringe the intellectual property rights (copyright, trademark, patent, design rights, trade secrets) of AqNova, its Buyers, its Vendors, or any third party in the performance of their services.

Technology suppliers must ensure that software, tools, and systems provided to AqNova are properly licensed and do not infringe third-party IP rights.

Vendors must not list products that infringe the intellectual property rights of third parties. Counterfeiting is prohibited. See Section 5.7, 5.8 and 7.4.6.

Suppliers must not reproduce, distribute, or use AqNova's brand assets, trademarks, or marketing materials without AqNova's prior written consent.

B. Confidentiality

Suppliers must protect AqNova's confidential information — including business plans, pricing structures, Buyer and Vendor data, technical systems, and commercial strategies — with the same level of care they would apply to their own most sensitive information, and in any event at least a reasonable standard of care.

Confidential information may only be used for the purposes of performing contracted services and may not be disclosed to third parties without AqNova's written consent, except where required by applicable law.

Obligations of confidentiality survive the termination of the commercial relationship for a minimum of 5 years, or the period required by applicable law if longer.

7.4.8 Legal Compliance & Regulatory Obligations

All suppliers must comply with applicable laws and regulations in all jurisdictions where they operate or where their goods and services are provided. The following specific legal compliance obligations are particularly material to AqNova's supply chain:

A. Export Controls & Sanctions

Suppliers must comply with applicable export control laws, including: US Export Administration Regulations (EAR); International Traffic in Arms Regulations (ITAR); EU Dual-Use Regulation (2021/821/EU); UK Export Control Order 2008.

Suppliers must not conduct transactions with parties on applicable sanctions lists (OFAC SDN; UN Security Council Consolidated List; EU restrictive measures; UK OFSI). Suppliers must screen their own customers and sub-suppliers against applicable sanctions lists.

Suppliers must not provide to AqNova goods, technology, or services that are subject to export license requirements without first obtaining the applicable license.

B. Customs & Trade Compliance

Logistics and freight suppliers must comply with applicable customs law in all import and export jurisdictions.

All product shipments must be accurately described in customs documentation — under-valuation, mis-classification, or falsification of customs documentation is prohibited and constitutes a material breach of this Code.

Country of origin declarations must be accurate. Suppliers must not misrepresent the country of origin of goods to circumvent tariffs, quotas, or trade restrictions.

C. Tax Compliance

All suppliers must comply with applicable tax law in their jurisdictions of operation, including: accurate tax filings and timely payment of taxes; VAT/GST registration and compliance where required; transfer pricing compliance for inter-company transactions.

AqNova does not condone or facilitate tax evasion or aggressive tax avoidance by its suppliers.

D. Modern Slavery & Forced Labour Compliance

All suppliers must comply with AqNova's Ethical Sourcing Policy (Section 6.2) and the modern slavery disclosure obligations applicable to them, including: UK Modern Slavery Act 2015 (where turnover threshold met); Australian Modern Slavery Act 2018; California SB 657; Canada S-211; and equivalent applicable national law.

Where required by national law, suppliers must publish their own Modern Slavery Statements and share the publication URL with AqNova on request.

7.4.9 Supply Chain Due Diligence & Transparency

AqNova's supply chain due diligence obligations extend into the supply chains of its suppliers. The following supply chain transparency and due diligence requirements apply to suppliers in high-risk categories:

A. Supply Chain Mapping & Transparency

High-risk category suppliers (apparel; textiles; electronics; food/agricultural; cosmetics; minerals/metals) must be able to identify their Tier 1 (direct) suppliers on request and provide information on the countries of origin, manufacturing facilities, and primary contact for each.

AqNova gives preferential recognition to suppliers who: publicly disclose their Tier 1 supplier list (e.g., through the Open Supply Hub — opensupplyhub.org); participate in the Sedex platform; or publish supply chain transparency reports.

Suppliers are encouraged to conduct their own supply chain mapping to Tier 2 level for high-risk commodities (cotton; mica; cobalt; cocoa; palm oil; natural rubber; natural stone).

B. Supplier Selection & Management

Suppliers are expected to apply equivalent ethical standards to their own suppliers and sub-contractors, including requirements on labour standards, environmental compliance, and business integrity.

Where a supplier discovers material non-compliance with this Code in their own supply chain (forced labour; child labour; significant environmental violation; corruption), they must: immediately notify AqNova; initiate corrective action; and cooperate with AqNova's investigation if requested.

C. Due Diligence Legislative Context

Suppliers who are independently subject to mandatory supply chain due diligence legislation must comply with their own obligations under these laws, and may be required to share relevant due diligence documentation with AqNova:

Germany LkSG (Lieferkettensorgfaltspflichtengesetz, 2023): companies with 1,000+ employees in Germany must conduct risk-based human rights and environmental due diligence in their supply chains.

France Loi de Vigilance (Law 2017-399): large French companies must publish and implement a vigilance plan addressing human rights and environmental risks in their supply chain.

EU CSDDD (2024/1760/EU): in-scope EU and non-EU companies must conduct due diligence on actual and potential adverse human rights and environmental impacts in their supply chains.

Norway Åpenhetsloven (2022): larger enterprises in Norway must conduct UNGPs-based human rights due diligence and publish annual reports.

A. Supplier Obligations — Worker Grievance Mechanisms

All suppliers with 10 or more direct workers must have a documented worker grievance mechanism through which workers can raise concerns about working conditions, labour rights, or Code violations without fear of retaliation.

The grievance mechanism must be accessible to all workers (including migrant workers and informal workers) and available in languages understood by workers at the facility.

Workers who raise grievances must not be subjected to retaliation, punishment, dismissal, or any form of adverse treatment.

Suppliers should consider third-party managed anonymous reporting channels for workers in higher-risk contexts.

B. Reporting Concerns to AqNova

Suppliers, their workers, and any person with knowledge of a potential Code violation are encouraged to report concerns to AqNova:

Supplier Code of Conduct violations: compliance@aqnova.co [Subject: Supplier Code Concern — [Company Name]].

Modern slavery or labour rights concerns in supply chains: compliance@aqnova.co [Subject: Supply Chain Worker Report].

Anti-bribery concerns (including concerns about AqNova employees): ethics@aqnova.co [CONFIDENTIAL].

All reports may be made anonymously. AqNova does not tolerate retaliation against good-faith reporters.

A. Self-Assessment & Annual Certification

All suppliers are required to complete AqNova's Supplier Code of Conduct Annual Self-Assessment (via the Supplier Portal or email to compliance@aqnova.co) within 30 days of the anniversary of their relationship commencement and on each annual renewal. The Self-Assessment requires the supplier to confirm compliance with each section of this Code, identify any areas of partial compliance, and outline improvement actions.

B. Third-Party Audits

C. AqNova's Right to Audit

AqNova reserves the right to conduct announced or unannounced audits of suppliers' operations and facilities (directly or through third-party auditors) with reasonable prior notice (except in cases of urgent concern about worker safety or material fraud, where no notice is required). Suppliers agree to: provide full and open access to facilities, documentation, records, and workers; ensure that workers can speak freely with auditors in private; not take retaliatory action against workers who participate in audits.

D. Consequences of Non-Compliance

7.4.12 Code of Conduct Acceptance & Annual Certification

All suppliers accept this Code as a condition of their commercial relationship with Arivon Holding Corporation. Acceptance is evidenced by:

Entering into or continuing a commercial relationship with AqNova after the Code's effective date (April 7, 2026).

Countersigning the Code of Conduct Acceptance Form (for new suppliers from April 2026 onward).

Completing the annual Supplier Code Compliance Self-Assessment.

7.4.13 Contact Information — Supplier & Partner Code of Conduct

AqNova Marketplace | Global Legal Footer Framework | Section 7.4: Supplier & Partner Code of Conduct

© 2026 Arivon Holding Corporation. All rights reserved. Effective April 7, 2026. Version 1.0.